Question of the Week: Calculating Generator Status

Posted on 1/21/2011 by James Griffin

Q. What is "generator status," and how do I calculate it?

A. Each and every person who produces hazardous waste is a generator and must determine his or her generator status each calender month. A facility’s generator status determines how stringently it is regulated and how long it may accumulate hazardous waste on site without a permit.

Three Categories of Waste Generator

Conditionally Exempt Small Quantity Generators (CESQGs) generate no more than 100 kilograms of hazardous waste per calender month [40 CFR 261.5(a)]. CESQGs are largely exempt from regulation, as long as they classify their waste and ensure that it is recycled or disposed of in an appropriate facility.

Small Quantity Generators (SQGs) generate more than 100 kilograms but less than 1,000 kilograms of hazardous waste per calender month [40 CFR 262.34(d)]. SQGs may accumulate hazardous waste on site without a permit for up to 180 days [40 CFR 262.34(d)].

Large Quantity Generators (LQGs) generate 1,000 kilograms or more of hazardous waste per calender month. LQGs may accumulate hazardous waste on-site without a permit for up to 90 days and have more paperwork obligations than SQGs [40 CFR 262.34(a)].

Don’t Count Wastes Not Subject to Substantive Regulation

As the following waste materials are not subject to substantive regulation, they do not count when calculating generator status:
  • Hazardous waste in manufacturing process units [40 CFR 261.4(c)]
  • Hazardous waste or tractability study samples [40 CFR 261.4(d), (e), (f)]
  • Ethyl alcohol, scrap metal, or petroleum refining wastes when recycled [40 CFR 261.6(a)(3)]
  • Empty hazardous waste containers [40 CFR 261.7(a)(1)]
  • Polychlorinated biphenyl (PCB) wastes managed under TSCA [40 CFR 261.8]
  • Hazardous wastes managed immediately on site in elementary neutralization units, wastewater treatment units, or totally enclosed treatment facilities [40 CFR 261.5(c)(2)]
  • Hazardous wastes recycled immediately without prior storage in an on-site process subject to 40 CFR 261.5(c)(3)
  • Used oil, spent lead-acid batteries, and universal wastes when managed under specific regulations [40 CFR 261.5(c)(4), (5), and (6)]
  • Wastes generated in laboratory cleanouts under 40 CFR Part 262 Subpart K [40 CFR 261.5(c)(7)]
Don’t Count Your Waste Twice

Generators must count their waste at the point of generation and should not re-count the same waste during the same calender month. This means that generators should NOT count when wastes are removed from a satellite accumulation area to a central accumulation area or when wastes are shipped off site. [40 CFR 261.5(d)]

If a generator reclaims hazardous waste for reuse on site, then the product and residues from the reclamation process do not count towards the generator status, as long as the hazardous waste was counted before reclamation. If the same stock of material is continually reused, then the generator must “count” the waste once a month [40 CFR 261.5(d)].

Tags: hazardous, RCRA, waste

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